It is common for multinational enterprises around the world to finance their associated subsidiaries in high-level tax jurisdictions through issuing debts rather than equities.
Introduction - The ever growing number of transactions involving MNEs over the past decade has resulted in transfer pricing becoming increasingly important. From the perspective of an MNE, transfer pricing offers the possibility to shift profits to affiliates located in low-tax jurisdictions. From the perspective of the tax authorities, profit shifting directly impacts on tax revenue meaning that appropriate countermeasures are necessary. Apart from that the tax authorities are becoming increasingly aware of the fact that transfer pricing adjustments can be a significant revenue booster. This ultimately leads to an increasing number of quite aggressive transfer pricing audits.
The term cloud is used by the information and communication technologies (ICT) industry to indicate, primarily, virtual platforms or infrastructures that allow the execution of codes (services, applications, among others) in various forms across multiple resources, with relevant data.
In this final part, Peter Wilson concludes his discussion of Article 12. Parts 1-3 appeared in the previous three issues of ITR.
In Parts 1 and 2, which appeared in the March and April issues, Maria Cecilia Rossi discussed Cloud Computing and its interaction with the concept of permanent establishment. Here, in Part 3, she concludes her discussion.
In Part I, Angelica Maria Orozco Diaz analysed the Intergovernmental Agreement between the USA and the UK in relation to FATCA. She continues her discussion here.
In Part 1, Maria Cecilia Rossi introduced the concept of cloud computing and examined its interaction with traditional international tax law concepts and theories, with particular reference to the concept of permanent establishment. In Part 2, Rossi continues this discussion.
Investment and Indirect Taxes
In Part I, Sylvia H. Torres Caro discussed how Colombia attracts foreign investment and focused her discussion on legal stability agreements put in place by Colombia and other Latin American countries. She concluded by briefly discussing the role played by Colombia’s double tax treaties in securing foreign direct investment. Part II continues this discussion.
International tax avoidance using trusts: How can Cyprus facilitate this form of tax planning?– Part II
In Part I, Iva Angelova introduced the concept of tax avoidance and explained how trusts are used in tax planning schemes. In Part II, she continues with a discussion on the use of trusts internationally and the role played by Cyprus in the world of tax planning.
EMAIL NEWSLETTER SIGN UP
- The Great HMRC Clampdown - Coming Next to Construction Intermediaries Learn more about this CPDcast
- Tax Planning - Farms, Agricultural Business and Development Land Learn more about this CPDcast
- Times They Are A Changing For Limited Liability Partners Learn more about this CPDcast
- Buying Property in the UK - Tax Risks and Opportunities Learn more about this CPDcast
- A Practical Guide for High Net Worth Migrants to the UK - Part One Learn more about this CPDcast